PRIVACY POLICY

Protecting the privacy of our clients and users of our site(s) is important to Calypso. This Privacy Policy explains how Calypso Technology, Inc., which hosts and administers the Calypso website, (Calypso, we, us and our), and our affiliates, collect, use, and disclose information you provide to us or which we otherwise collect, including personal data, by which we mean information that allows us to determine your identity when you engage with us.

Calypso provides innovative cross-asset front-to-back technology solutions for complex financial markets through its software platform. We also provide educational and promotional resources and other promotional material through our website (Website). The use of our Website is subject to our terms of use and this policy is incorporated into and forms part of those terms.

Our contact details are set out at the end of this policy. We are the controller in relation to the personal data processed in accordance with this policy (except where this policy explains otherwise).

Please read the following carefully to understand our views and practices regarding your personal data and how we will treat it.

Information we collect about you

Website, Account and General Communications

In order to provide materials and services to you, when you visit our Website, request white papers or other materials from us, register for events, or contract with us, we will collect data from you. For example, Calypso may receive your personal data when you:

Communicate or interact with Calypso on-line or off-line, including for access to our platform be it installed on your premises or in the cloud.

We refer collectively to these interactions as the “Website Services”. We explain below how we collect and use information collected through the Website Services in the related section below.

Information we collect

We (or third-parties acting on our behalf, as set out below) may collect your information, including your personal data, when providing the Website Services including:

Your name.

Who you work for, the type of company you work for and your job function or department.

Your address, phone number, email address or other contact details (these details may relate to your work or to you personally, depending on the nature of our relationship with you or your employer).

Information about you that you give us by communicating with us by phone, by e-mail, via our Website or otherwise. It includes information you give us or that we obtain when you use our Website, enquire about a product, subscribe to, or order, access to our software platform, enter a promotion or survey, or contact us to report a problem, or do any of these things on behalf of your employer.

Information about events to which you or your colleagues are invited, and your personal data and preferences to the extent that this information is relevant to organising and managing those events (for example, your dietary requirements);

Information about how you use our Website including pages visited and other interactions with the Website;

The browser software and operating system you use to access the Website, your IP address and/or mobile device ID.

How We Use Your Information

Calypso may use personal data for various purposes when you engage with us based on different reasons. Data protection law in Europe contains a number of "lawful bases" – which are really legal justifications which mean organisations like us are allowed to have your personal data in the first place. For our EU users, we have been careful to ensure we have a lawful basis for all data we have. Our lawful bases include:

Performing the contract we have with youIn certain circumstances, we need your personal data to comply with our contractual obligation to deliver Calypso products and services. For example, if you want to order Calypso products or services through our Website or obtain support services, we need your name and contact details so we can communicate with you and provide the software or service.

Legal complianceTo comply with any applicable law, regulation, legal process, or governmental request. We may pass on details of people involved in fraud or other criminal activity to law enforcement and tax laws require us to retain records of orders and payments for Calypso software and related services, which can include contact details at our corporate clients.

Send administrative information or changes to contract terms or policies. Where we make updates to terms and policies we are required under certain laws to notify you of these changes and under our contract with you. Other administrative communications, may be necessary in order for us to perform our obligations under the contract with you, or may be sent out in line with our legitimate interests.

Legitimate interests This is a technical term in data protection law which really means we have a good and fair reason to use your data and we do so in ways which does not hurt your interests and rights. We sometimes require your data to pursue our legitimate interests in a way which might reasonably be expected as part of running our business and which does not materially impact your rights, freedom or interests.

Improve and develop the Website. We look for ways to innovate and improve our Website for all our users. We will use information about how you use the Website, including how you interact with various aspects of the Website, the duration for which you use the Website and content that is of interest to you, in order to understand how our users use the Website and what content works well. It is in our legitimate interests to use personal data in this way to develop an improved Website.

Research and analyse how our Website is used via cookies, web beacons and other similar technologies. We use your personal data in our legitimate interests to understand how you interact with our Website and to deliver relevant content to you online.

Diagnose and fix technical issues and monitor the security of our environments. We need to understand how our Website is performing in order to prevent and address any issues that may present themselves with regard to technical and security operations. We may process your personal data for this purpose in our legitimate interests to protect the integrity of the Website. It is also in our legitimate interests to process your personal data to protect our rights or property, or the security or integrity of our Website.

If we intend to process your personal data for a purpose other than that set out above, we will provide you with information prior to such processing.

Cookies and other technologies

Cookies are small text files placed in visitors’ computer browsers to store their preferences. The Website and our third party partners collect and store information that is generated automatically as you use it, including your preferences and anonymous usage statistics. When you visit the Website, we and our third-party service providers receive and record information on our server logs from your browser and from cookies and similar technology.

We may use information collected through these tracking technologies to remember information so that you won’t have to re-enter it on subsequent visits, to provide and monitor the effectiveness of the Website and for other purposes. Most browsers allow you to block and delete cookies, though depending on your mobile device you may not be able to delete tracking technologies from your device. Deleting or blocking cookies and other tracking technology may cause the Website to not work properly. A number of cookies and similar technologies we use last only for the duration of your Website session and expire when you close your browser. Others are used to remember you when you return to use our Website and will last for longer.

We use these cookies and other technologies on the basis that they are necessary for the performance of a contract with you, or because using them is in our legitimate interests (where we have considered that these are not overridden by your rights), and, in some cases, where required by law, where you have consented to their use.

We use the following types of cookies:

Strictly necessary cookies. These are cookies that are required for the operation of our Website and under our terms with you. They include, for example, cookies that enable you to log into secure areas of our Website, use a shopping cart or make use of e-billing services.

Analytical/performance cookies. They allow us to recognise and count the number of visitors and to see how visitors move around our Website when they are using it. This helps us for our legitimate interests of improving the way our Website works, for example, by ensuring that users are finding what they are looking for easily.

Google Tag Manager: we use Google Tag Manager. This service allows website tags to be managed via an interface. Tags are small elements of code that are used, for example, to measure traffic and visitor behaviour, to understand the effect of online advertising and social channels, to set up remarketing and orientation towards target groups, and to test and optimize websites. Google Tag Manager only implements tags. This means that no cookies are used and, as a result, no personal data is recorded. We list it here for completeness and to be transparent about the tools we use. If deactivation has been performed at a domain or cookie level, this remains in place for all tracking tags if these are implemented with Google Tag Manager;

Google Analytics: to help us improve our Website, we use Google Analytics, a web analytics service. Google Analytics uses cookies to help the Website analyze how visitors use the Website. The information generated by the cookie about your use of the Website (including your IP address) will be transmitted to and stored by a Google server in the United States. Google uses this information for the purpose of evaluating your use of the website, compiling reports on website activity for website operators and providing website operators with other services relating to website activity and internet usage. You can prevent the storage of data relating to your use of the Website and created via the cookie (including your IP address) by Google as well as the processing of this data by Google by downloading and installing the browser plug-in available at the following link: https://tools.google.com/dlpage/gaoptout?hl=en;

Functionality cookies. These are used to recognise you when you return to our Website. This enables us, subject to your choices and preferences, to personalise our content, greet you by name and remember your preferences (for example, your choice of language or region).

Customers can configure their browser preferences not to accept these cookies however this may result in reduced functionality. For more information about how to turn cookies off see below or visit http://www.youronlinechoices.com/uk/

Disabling cookies

The effect of disabling cookies depends on which cookies you disable but, in general, the Website may not operate properly if all cookies are switched off. If you disable cookies, there may be reduced functionality in relation to the Website.

If you want to disable cookies on our Website, you need to change your website browser settings to reject cookies. How you can do this will depend on the browser you use. Further details on how to disable cookies for the most popular browsers are set out below:

Where you have not set your permissions, we may also separately prompt you regarding our use of cookies on the Website.

Our promotional updates and communications

Where permitted in our legitimate interest or with your prior consent where required by law, we will use your personal data for marketing analysis and to provide you with promotional update communications by email, SMS or telephone about our products/services.

You can object to further marketing at any time by selecting the "unsubscribe" link at the end of all our marketing and promotional update communications to you, or by sending us a message through our website at news@calypso.com with “Unsubscribe” in the subject line.

Who we give your information to

We may share your personal data with:

Any member of our group, which means our subsidiaries, , who support our processing of personal data under this policy. If any of these parties are using your information for direct marketing purposes, we will only transfer the information to them for that purpose with your prior consent.

Appropriate third parties including:

our business partners, customers, suppliers and sub-contractors for the performance of any contract we enter into or other dealings we have in the normal course of business with you or the person that you work for;

our auditors, legal advisors and other professional advisors or service providers;

service providers – see vendor list below.

Other disclosures we may make

We will disclose your personal data to third parties:

In the event that we sell or buy any business or assets, in which case we will disclose your personal data to the prospective seller or buyer of such business or assets subject to the terms of this privacy policy.

If Calypso Technology UK Ltd., or its affiliates, or substantially all of their assets are acquired by a third party, in which case personal data held by it about its customers will be one of the transferred assets.

If we are under a duty to disclose or share your personal data in order to comply with any legal obligation, or in order to enforce or apply our terms of supply terms and other agreements with you or the company you work for; or to protect the rights, property, or safety of Calypso Technology Ltd., our affiliates, our customers, or others. This includes exchanging information with other companies and organisations for the purposes of fraud protection and to prevent cybercrime.

Where do we store your information?

The data that we process in relation to you may be transferred to, and stored at, a destination outside the European Economic Area (EEA) that may not be subject to equivalent data protection law. It may also be processed by staff situated outside the EEA who work for us or for one of our suppliers.

We may transfer your personal data outside the EEA:

In order to store it.

In order to enable us to provide goods or services to and fulfil our contract with you or the company your work for. This includes order fulfilment, processing of payment details, and the provision of support services.

Where we are legally required to do so.

In order to facilitate the operation of our group of businesses, where it is in our legitimate interests and we have concluded these are not overridden by your rights.

Where your information is transferred outside the EEA, we will take all steps reasonably necessary to ensure that your data is subject to appropriate safeguards, such as relying on a recognised legal adequacy mechanism, and that it is treated securely and in accordance with this privacy policy. We may transfer your personal data to the following countries outside the EEA:

Any member of our group, which means our subsidiaries, our ultimate holding company and its subsidiaries, the locations of which are available at this link, http://www2.calypso.com/locations, we use European Commission approved contractual clauses for transfers (referred to as "Model Clauses");

Our vendors, details of which are set out below, and for these purposes we use Model Clauses:

Customer relationship management solution provider – cloud computing industry – based in the United States

Press release distribution and regulatory disclosure provider – investment industry – based in the United States;

Web analytics service provider – ecommerce and Internet industry – based in the United States;

IT support services provider – IT industry – based in the United States;

Expenses services provider – cloud applications and platform services industry – based in the United States;

Proprietary issue tracking product – project management and IT industry – based in the United States;

Project management software provider – professional services automation industry – based in the United States.

How we protect your information

All information you provide to us is stored on our servers. Where we have given you (or where you have chosen) a password which enables you to access certain parts of our Website, you are responsible for keeping this password confidential. We ask you not to share a password with anyone. Access to and use of password protected and/or secure area of any Calypso site is permitted to authorized users only.

The transmission of information via the internet is not always completely secure. Although we will do our best to protect your personal data, we cannot guarantee the security of your data transmitted to our Website; any transmission is at your own risk. Once we have received your information, we will use strict procedures and security features to try to prevent unauthorised access.

Our Website may, from time to time, contain links to external sites. We are not responsible for the privacy policies or the content of such sites.

How long we keep your information

We retain personal data for as long as you have an account with us in order to meet our contractual obligations to you and for six years after that to identify any issues and resolve any legal proceedings, or, where you obtain Website Services only, for thirty months. We may also retain aggregate information beyond this time for research purposes and to help us develop and improve our services. You cannot be identified from aggregate information retained or used for these purposes.

Your rights

You have the right under certain circumstances:

to be provided with a copy of your personal data held by us;

to request the rectification or erasure of your personal data held by us;

to request that we restrict the processing of your personal data (while we verify or investigate your concerns with this information, for example);

to object to the further processing of your personal data, including the right to object to marketing (as mentioned in 'Our promotional updates and communications' section);

to request that your provided personal data be moved to a third party.

Your right to withdraw consent:

Where the processing of your personal data by us is based on consent, you have the right to withdraw that consent at any time by contacting us. You can also change your marketing preferences at any time as described in 'Our promotional updates and communications' section;

The Information Commissioner is the supervisory authority in the UK and can provide further information about your rights and our obligations in relation to your personal data, as well as deal with any complaints that you have about our processing of your personal data.

Changes to this policy

Any changes we make to our privacy policy in future will be posted on our Website at http://www2.calypso.com/Privacy and, in relation to substantive changes, will be notified to you by e-mail. This policy was last updated on 18 May 2018.

You may also make those requests by calling toll free: 1-866-433-2496.

Please be aware that we do not accept or process requests through other means (e.g., via fax, social media, email addresses, etc.).

When you make a request, we may ask you to provide verifying information, such as your name, email, or phone number. We will review the information provided and may request additional information via email or other means to ensure we are interacting with the correct individual. Please also be aware that making any such request does not ensure complete or comprehensive removal or deletion of Personal Information or content you may have posted, and there may be circumstances in which the law does not require or allow us to fulfill your request.

Children

Our Services are not directed to children, and we do not knowingly collect Personal Information from children under the age of 16. If you learn that a child has provided us with Personal Information, then you may contact us as indicated above.

Do Not Track

Calypso does not currently take steps to respond to browsers’ “Do Not Track” signals as no uniform standard to respond to such signals has been developed at this time.